ANTI-MONEY LAUNDERING & COMBATINGTHE FINANCING OF TERRORISM POLICY(Last updated on: 09 November 2021)
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Tradit Ltd. is licensed and regulated by the FSC Mauritius lic. no GB21026376. The company is legally obliged to follow all laws of
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Table of Contents
Part A. LEGISLATIVE AND REGULATORY BACKGROUND ....................................................................... 3
1. What is Money Laundering? ........................................................................................................... 3
2. Legislative References .................................................................................................................... 4
3. Regulatory References ................................................................................................................... 4
4. Industry Guidance ..................................................................................................................................5
5. Offences, Penalties and Defences ................................................................................................... 5
5.1 Offences and Penalties ...................................................................................................................... 5
5.2 Defences ................................. ........................................................................................................... 7
6. Sanctions Regime ...................................................................................................................................8
Part B. OVERVIEW AND POLICY FRAMEWORK.................................................................................... 8
7. Introduction ...........................................................................................................................................8
8. Purpose and Scope ........................................................................................................................ 9Part C. GOVERNANCE, AML AND CFT SYSTEMS AND CONTROLS ......................................................... 99. Governance and Core Responsibilities ............................................................................................ 9
9.1 Wider Governance Arrangements ..................................................................................................... 9
9.2 Core Responsibilities ......................................................................................................................... 9
10. Risk Management Framework .................................................................................................... 11
11. Client Onboarding and Acceptance............................................................................................. 11
12. Ongoing Client Monitoring ......................................................................................................... 13
13. Internal and External Reporting .................................................................................................. 13
14. Record Keeping ..................................................................................................................................14
APPENDICES
Appendix 1. Associated Policies and Procedures ............................................................................... 15
Appendix 2. Glossary ....................................................................................................................... 16

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PART A. LEGISLATIVE AND REGULATORY BACKGROUND
1.

WHAT IS MONEY LAUNDERING?

The Anti-Money Laundering regulations require a fundamental understanding of the processes
that can be involved in money laundering, and require that you respond appropriately to any
knowledge or suspicions that these processes may be taking place. This section of the AML &CFT Policy (hereinafter the “Policy”) explains what money laundering is, the offences and thepenalties.
The main objective of money laundering is to exchange the initial proceeds of an illegal activity
with a financial asset or other valuables to give legitimacy to such proceeds and to conceal thetrue source of the funds.
Simply put, money laundering is any process whereby funds derived from criminal activity,
including terrorist financing, are given the appearance of being legitimate by being exchanged
for “clean” money. Participating in the handling of such funds is illegal, and it can also be illegal
to become involved with them “indirectly” through knowledge or suspicion.
The wider definition of money laundering and activities controlled by the statutory framework
was introduced in the Money Laundering, Terrorist Financing and Transfer of Funds Regulations
20171; where money laundering was defined as:▪ concealing, disguising, converting, transferring or removing criminal property;▪ entering into or becoming concerned in an arrangement which a person knows or suspects
facilitates the acquisition, retention, use or control of criminal property;▪ acquiring criminal property, using criminal property; or possession of criminal property.
The process of money laundering can be divided into three sequential stages:(1) Placement. At this stage funds are converted into financial instruments, such as checks,bank accounts, and money transfers, or can be used for purchasing high-value goods thatcan be resold. They can also be physically deposited into banks and non-bank institutions(e.g., currency exchangers). To avoid suspicion by a company, the launderer may as wellmake several deposits instead of depositing the whole sum at once, this form of placement
is called smurfing.
(2) Layering. Funds are transferred or moved to other accounts and other financial
instruments. It is performed to disguise the origin and disrupt the indication of the entitythat made the multiple financial transactions. Moving funds around and changing in theirform makes it complicated to trace the money being laundered.
(3) Integration. Funds get back into circulation as legitimate to purchase goods and services.

2.

LEGISLATIVE REFERENCES

1 UK government’s formal guidance on rules on anti-money laundering, which implements the provisions of EU’s 4th Directive

on Money Laundering.
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As a legal entity regulated in Mauritius, Tradit Ltd (hereinafter the “Company”) is required tocomply with local regulations.
Mauritius brought a number of amendments to its AML/CFT framework through the Finance(Miscellaneous Provisions) Act 2018, Act 11 of 2018, which was gazetted on 9 August 2018 inGovernment Gazette 71 of 2018. The relevant amendments introduced by the Finance(Miscellaneous Provisions) Act 2018 are in force and aim at strengthening the national
AML/CFT framework by, inter alia:(a) enhancing the existing legal framework for preventive measures that apply to financial
institutions and Designated Non-Financial Businesses and Professions (“DNFBPs”);(b) extending the scope of the Financial Intelligence and Anti-Money Laundering Act(“FIAMLA”) to include proliferation financing;(c) establishing a legal framework to support the National Risk Assessment exercise;(d) providing a general penalty for contravention of those provisions of the FIAMLA for which
no specific penalty was set out.
In addition, a new set of regulations namely, the Financial Intelligence and Anti-Money
Laundering Regulations (“FIAML Regulations 2018”) were promulgated on 28 September 2018
and became effective on 01 October 2018. The FIAML Regulations 2018 revoked the Financial
Intelligence and Anti-Money Laundering Regulations 2003 and address, inter alia, the following
FATF requirements:(a) Customer due diligence;(b) Politically exposed persons;(c) Correspondent banking;(d) Money or value transfer services;(e) New technologies;(f) Wire transfers;(g) Reliance on third parties; and(h) Internal control and foreign branches and subsidiaries.
On 21 May 2019, the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban)
Sanctions Act 2019 and the Anti-Money Laundering and Combatting the Financing of Terrorism
and Proliferation (Miscellaneous Provisions) Act 2019 were enacted and both acts came into
operation on the 29 May 2019.
The United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act
2019enables Mauritius to implement the measures under all the United Nations Security
Council Resolutions and deal with other matters of international concern, and to give effect to
Article 41 of the Charter of the United Nations.

3.

REGULATORY REFERENCES

The requirements to prevent and detect money laundering and to counter terrorist financing
arise from the FIAMLA and the FIAML Regulations 2018.

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4.

INDUSTRY GUIDANCEThe AML and CFT regulatory requirements are largely pulled together by a set of industry
guidance notes, provisions of which the Company aims to incorporate into its policies,
procedures, and day-to-day operations.
The Company is adhering to the following guidance documents:(1) UK Financial Conduct Authority (FCA);▪ FCA’s Financial Crime: a guide for firms, Parts I & II, 2016
▪ FCA’s Systems and Controls (SYSC) Rules that require senior management to establish
appropriate procedures and controls to implement the requirements of the Money
Laundering, Terrorist Financing and Transfer of Funds Regulations (MLR), and to
manage the risks of the Company’s products and services being used for purposes offinancial crime;(2) Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector
Parts I, II, and III, 2017
(3) Financial Action Task Force (FATF) Recommendations that are recognised as theinternational standard for combating money laundering and the financing of terrorism andproliferation of weapons of mass destruction.

5.

OFFENCES, PENALTIES AND DEFENCES
5.1. Offences and Penalties

Section 3 of the FIAMLA states:(1) Any person who –(a) engages in a transaction that involves property which is, or in whole or in part directly
or indirectly represents, the proceeds of any crime; or(b) receives, is in possession of, conceals, disguises, transfers, converts, disposes of,removes from or brings into Mauritius any property which is, or in whole or in part
directly or indirectly represents, the proceeds of any crime, where he suspects or has
reasonable grounds for suspecting that the property is derived or realized, in whole orin part, directly or indirectly from any crime, shall commit an offence.
(2) A bank, financial institution, cash dealer or member of a relevant profession or occupationthat fails to take such measures as are reasonably necessary to ensure that neither it nor
any service offered by it, is capable of being used by a person to commit or to facilitate
the commission of a money laundering offence or the financing of terrorism shall commit
an offence.
(3) In FIAMLA, reference to concealing or disguising property which is, or in whole or in part,
directly or indirectly, represents, the proceeds of any crime, shall include concealing or
disguising its true nature, source, location, disposition, movement or ownership of or rights
with respect to it.
Section 4 of the FIAMLA states:www.axiory.com

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Without prejudice to section 109 of the Criminal Code (Supplementary) Act, any person who
agrees with one or more other persons to commit an offence specified in section 3(1) and (2)shall commit an offence.
Section 5 of the FIAMLA states:(1) Notwithstanding section 37 of the Bank of Mauritius Act 2004, but subject to subsection(2), any person who makes or accepts any payment in cash in excess of 500,000 rupees oran equivalent amount in foreign currency, or such amount as may be prescribed, shallcommit an offence.
(2) Subsection (1) shall not apply to an exempt transaction.
Section 8 of the FIAMLA states:(1) Any person who –(a) commits an offence under this Part; or(b) disposes or otherwise deals with property subject to a forfeiture order undersubsection (2), shall, on conviction, be liable to a fine not exceeding 2 million rupees
and to penal servitude for a term not exceeding 10 years.
(2) Any property belonging to or in the possession or under the control of any person who isconvicted of an offence under this Part shall be deemed, unless the contrary is proved, tobe derived from a crime and the Court may, in addition to any penalty imposed, order thatthe property be forfeited.
(3) Sections 150, 151 and Part X of the Criminal Procedure Act and the Probation of Offenders
Act shall not apply to a conviction under this Part.
Section 16(3) (A) of FIAMLA states:
Legal consequences of reporting
Any person who fails to comply with subsection (1) shall commit an offence and shall, on
conviction, be liable to a fine not exceeding 5 million rupees and to imprisonment for a term
not exceeding 10 years.
Section 17(C) (6) of FIAMLA states:
Customer due diligence requirements
Any person who knowingly provides any false or misleading information to a reporting person
in connection with CDD requirements under the FIAMLA or any guidelines issued under thisAct shall commit an offence and shall, on conviction, be liable to a fine not exceeding 500, 000
rupees and to imprisonment for a term not exceeding 5 years.
Section 19 of FIAMLA states:
Offences relating to obligation to report and keep records and to disclosure of Information
prejudicial to a request(1) Any bank, cash dealer, financial institution or member of a relevant profession or
occupation or any director, employee, agent or other legal representative thereof, who,
knowingly or without reasonable excuse –(a) fails to –i.
supply any any information requested by the FIU under section 13(2) or 13(3)within the date specified in the request;ii.
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iii.

any person who fails to comply with sections 17 to 17G shall commit an offence
and shall, on conviction, be liable to a fine not exceeding 10 million rupees andto imprisonment for a term not exceeding 5 years.
(b) destroys or removes any record, register or document which is required under FIAMLA
or any regulations;(c) facilitates or permits the performance under a false identity of any transaction fallingwithin this Part, shall commit an offence and shall, on conviction, be liable to a fine notexceeding one million rupees and to imprisonment for a term not exceeding 5 years.
(2) Any person who –(a) falsifies, conceals, destroys or otherwise disposes of or causes or permits thefalsification, concealment, destruction or disposal of any information, document ormaterial which is or is likely to be relevant to a request to under the Mutual Assistancein Criminal and Related Matters Act 2003; or(b) knowing or suspecting that an investigation into a money laundering offence has beenor is about to be conducted, divulges that fact or other information to another person
whereby the making or execution of a request to under the Mutual Assistance in
Criminal and Related Matters Act 2003 is likely to be prejudiced, shall commit anoffence and shall, on conviction, be liable to a fine not exceeding one million rupees
and to imprisonment for a term not exceeding 5 years.
Section 19E of FIAMLA states:
Duty to provide information
Any person who fails to comply with a request made under subsection (2)(b) shall commit anoffence and shall, on conviction, be liable to a fine not exceeding one million rupees and to
imprisonment for a term not exceeding 5 years.
FIAML Regulations 2018:
Regulation 33 states that any person who contravenes these regulations shall commit anoffence and shall on conviction, be liable to a fine not exceeding one million rupees and to
imprisonment for a term not exceeding 5 years.

5.2. Defences
There are certain defences available for some of the offences listed above. The main defence
relevant to the Company’s employees is the defence of having made an 'authorized disclosure',
which is a disclosure made:▪ before an offence is committed;▪ while it is being committed but an employee started the act at a time when, because they
did not know or suspect that the property constituted or represented a person’s benefit
from criminal conduct, the act was not an offence, and the disclosure is made on theemployee’s own initiative and as soon as practicable to make it;▪ after the offence was committed, but there is a good reason for the employee’s failure to
make the disclosure before the act was done, and the disclosure is made on the employee’s
own initiative and as soon as it is practicable to make it.

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If an employee makes a disclosure to the MLCO in accordance with the Procedure for Internal
Suspicious Activity Reporting as specified in the AML & CFT Procedures Manual, then that
disclosure will be sufficient for the employee to rely on this defence, provided a disclosure ismade before any offence has been committed. This is why it is so important for all employees
to read this Policy carefully, comply with its requirements and act quickly.
The MLCO will then decide whether to report the suspicion to the Financial Intelligence Unit
(FIU). Where a suspicion is reported, if the MLCO does not receive a “refusal to proceed” fromthe FIU within a 7-day period then the employee can proceed with that transaction. Where a“refusal to proceed” is received there is a further period of 30 days for the FIU to follow up
their refusal with further instructions. If no further information is received within 31 days, theemployee can proceed with the transaction.
If the MLCO submits suspicious activity report to the FIU, an employee must discuss with the
MLCO what information can be given to the client, so that this does not result in an offence oftipping off.

6.

SANCTIONS REGIME

There is a separate but related sanctions regime that imposes restrictions on the Company’s
ability to do business with those persons and entities on UN and European Union sanctions
lists. Some entries on the lists are specific to a particular person or entity and others are general
financial sanctions on all persons and entities in a particular jurisdiction. Screening of all clients
against sanctions lists in World-Check2 is an integral part of the Company’s KYC and Client Due
Diligence procedures, and is done, both, when accepting an application from a new client, and,regularly during the business relationship with the client. The Company’s Client Acceptance
Policy (CAP) stipulates that application from a client, where they are identified as true matchon the sanctions list during the KYC procedure, shall be rejected and no business activity shallbe initiated.

PART B. OVERVIEW AND POLICY FRAMEWORK7.

INTRODUCTION

It is of critical importance for the Company’s integrity and reputation, to be able to identify,
report, and take precautions to guard against money laundering and financing of terrorism. The
nature of the Company’s business requires it to abide by anti-money laundering (AML) andcountering the financing of terrorism (CFT) legislation and regulation that apply to the trading
activities. In addition, the Company may be particularly attractive to individuals seeking toclean-up money due to non-face-to-face nature of the services.
In order to prevent the criminals from using the Company’s products and services forlaundering the proceeds of crime, it is required to establish appropriate and proportionate to2

World-Check is a database and a tool that is used by financial institutions globally, to efficiently screen clients, associates,transactions and employees for potential risk. The Database covers politically exposed persons, persons on sanction lists andother potentially high-risk individuals worldwide.
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the level of risk, systems and controls, and ensure their effective implementation. Therefore,
this Policy is designed to ensure that the Company has a defined and approved by senior
management overarching framework to comply with all applicable anti-money laundering andcountering the financing of terrorism legislation and regulations.
The Policy is supplemented by AML & CFT Procedures Manual and other Associated Policies
and Procedures, full list of which can be found in Appendix 1 to this Policy, designed to ensure
AML & CFT compliance during the day-to-day operations of the Company.

8.

PURPOSE AND SCOPE

The principal objectives of this Policy are to:▪ prevent the Company from being used by money launderers to further their illicit business;▪ define a framework to enable the Company to assist law enforcement agencies in identifying
and tracking down money launderers and their criminal property;▪ ensure that the Company remains compliant with all relevant AML, CFT and sanctions
legislation and regulations;▪ inform all relevant employees about the obligations of the Company and their obligations inrelation to complying with AML and CFT laws and regulations.
This Policy applies to all employees of the Company, its vendors, partners, and any external
parties involved in client referral, client onboarding and transaction processing.

PART C. GOVERNANCE, AML AND CFT SYSTEMS AND CONTROLS
9.

GOVERNANCE AND CORE RESPONSIBILITIES
9.1. Wider Governance Arrangements

This Policy is part of the Company’s risk management framework, alongside its arrangements
for assessing and mitigating risks (including financial crime risks), senior management’s
formalized roles and responsibilities, regular reporting to the board, KYE Policy and Procedures,
employee training and awareness arrangements. These arrangements are collectively designed
to ensure that the Company:▪ conducts its business in line with the law and proper standards;▪ pro-actively identifies and prevents financial crime risks it is exposed to.
9.2. Core Responsibilities
Approval:This Policy was approved by decision of the Company’s Executive Board. The Chief Executive
Officer ensures the Policy is reviewed annually, and, ad-hoc, as legislative and regulatory
developments dictate, and, taking into account regular compliance reviews and audit reports.
Delegated authority to make updates and amendments:
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The Chief Risk & Compliance Officer is responsible for updating the Policy, subject to an
approval from Executive Board, to:▪ reflect changes in relevant legislation, regulations and external guidance, where these do
not require significant changes in the Company’s internal practices and processes;▪ update job titles and roles;▪ update the list of associated policies and procedures;▪ make minor drafting and presentational changes;▪ make any other changes that do not substantively change the provisions of the Policy or
result in or require significantly different practices and procedures.
In addition, the Chief Risk & Compliance Officer may issue clarifying instructions and guidancematerials as to the scope of the Policy and its operation.
Implementation:
The responsibilities for approving and implementing the Anti-Money Laundering, Combating
the Financing of Terrorism and sanctions policies are outlined below:(1) The Executive Board:▪ reviews the financial crime policies and procedures, suggest changes and approvesthem;▪ reviews regular financial crime reports and annual report prepared by Money
Laundering Compliance Officer;▪ reviews the adequacy and effectiveness of the AML and CFT systems and controls
employed.
(2) The Chair of the Executive Board it responsible for:▪ the Company’s policies and procedures for countering the risk that it might be used tofurther financial crime.
(3) The Chief Risk & Compliance Officer3 is responsible for:▪ appointing the Money Laundering Compliance Officer, and providing direction to, andoversight of the Company’s AML & CFT strategy;▪ commissioning at least annually a report from the MLCO on the operation andeffectiveness of the firm’s systems and controls to combat money laundering andterrorist financing, and taking any necessary action to remedy deficiencies identified by
the report in a timely manner;▪ reviewing the performance of the MLCO;▪ establishing appropriate policies, controls and procedures to mitigate and manage
effectively the risks of money laundering and terrorist financing;▪ ensuring AML and CFT policies and procedures are kept up-to-date;▪ overseeing the development and reviewing all financial crime and compliance policies
including AML & CFT Policy;▪ monitoring compliance with all relevant laws, regulations and policies and reporting any
material or relevant non-compliance to the Executive Board.
(4) MLCO:▪ oversees the the Company’s compliance with the rules on systems and controls againstmoney laundering;
3

Whenever this responsibility is shared, the annual MLCO report and MLCO performance is to be reviewed by the higher
standing senior manager
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▪ ensures the establishment and maintenance of adequate and effective AML & CFT risk
management systems and controls;▪ monitors day-to-day compliance with the AML & CFT policies and procedures;▪ acts as the focal point for all issues related to ML and TF and primary interface with theregulatory authorities and law enforcement agencies.
The senior managers’ prescribed responsibilities and key responsibilities are formalised in the
Company’s Senior Management Structure, Roles & Responsibilities Statement.
All relevant employees4 are required at all times to comply with this Policy, associated AML and
CFT Procedures Manual and Operational Guidelines. Non-compliance by employees with thesepolicies and procedures may be considered as gross misconduct and could result in a
disciplinary offence which could lead to dismissal and depending on the nature of the issue, theemployee will possibly be subjected to criminal proceedings.

10. RISK MANAGEMENT FRAMEWORK
To facilitate and ensure compliance with AML & CFT laws and regulations and sanctions regime,
the Company is actively implementing a set of measures, consisting of policies, procedures,internal systems and controls. The development and implementation of such adequate
measures and their effectiveness, is managed and overseen by the Company’s senior
management. These measures are applicable to the Company, its vendors, partners, and any
external parties involved in client referral, client onboarding and transaction processing.
This section of the Policy provides an overview of the internal adopted measures, while themore detailed procedures are outlined in the AML & CFT Procedures Manual and shall becomplied with by all relevant employees, alongside this Policy document.
Below is the summary of internal measures and controls, adopted by the Company andgoverning its day- to-day operations:▪ the Company’s governance structure allows for adequate segregation of functions between
senior managers in charge of oversight and effective management of all matters related tofinancial crime risks, and is properly formalized in the Statement of Roles & Responsibilities
document;▪ the senior managers’ roles and assigned responsibilities in relation to managing financial
crime risks, developing and providing oversight over the firm’s internal systems and controls
are clearly defined in the Statement of Roles & Responsibilities approved by the Company’s
Executive Board and Supervisory Board (if applicable);▪ the financial crime risks are identified and assessed as part of the Company’s business-widerisk assessments and AML risk assessments, which are produced annually and, whennecessary, or as required by the senior management. The priority is given to the risks thathave a greater chance of materializing, and may cause a bigger impact for the Company,
and, to adequate allocation of resources required to manage the risks effectively;
4

A relevant employee, is one whose work is: relevant to the firm’s compliance with any requirement in the ML Regulations;or otherwise capable of contributing to the: a) identification or mitigation of the risks of ML/TF to which the firm’s business issubject; or b) prevention or detection of ML/TF in relation to the firm’s business.
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▪ the sufficient level of oversight on the part of the Executive Board is established throughregularly produced management information, that also ensures the effectiveness of thedevelopment and implementation of the measures and remediation plans, designed totackle the financial crime risks identified during risk assessments.
The following management information is produced internally:▪ monthly high-level financial crime reports summarizing critical KPIs;▪ quarterly detailed financial crime reports (incl. AML reports);▪ money laundering risk assessments produced at least annually;▪ annual report prepared by the MLCO and reviewed by the Executive Board;▪ internal audit reports prepared annually or as often as required.
Company does not underestimate the importance of the role that its employees play in tacklingmoney laundering and other financial crime risks, as well as safeguarding the integrity,
reputation and high-standards of conduct within the Company. The Company’s vetting process
and KYE policies, therefore, ensure the integrity and expertise of all relevant employees on an
ongoing basis. All relevant employees, including MLCO and senior managers, undergo regular
AML training and awareness sessions and are kept aware of their responsibilities andobligations in respect to AML and CFT, as well as recent legislative and regulatory developmentsin this area, and any changes in the Company’s policies and procedures.

11. CLIENT ONBOARDING AND ACCEPTANCE
The following are the broad guidelines in respect to client onboarding:(a) the clients undergo identification document and face match verification through an
automated system, equipped with trusted computer vision technology, that uses machinelearning to quickly and accurately ensure the authenticity and validity of the client’s ID andverify the client’s identity. The detailed procedure is stipulated in the Client Identification
and Due Diligence section of the AML & CFT Procedures Manual. It is considered that the
automated client identity verification fully replaces face-to-face identity verification;(b) all clients are screened against World-Check database, in order to ensure that the identityof the client in question does not match with any persons who are known to have criminal
background or are subject to sanctions, or is associated with banned entities such asindividual terrorists or terrorist organizations, etc. In addition, the clients are screened
against records of PEPs (including their close associates and family members), which arealso covered in the World-Check database;(c) all clients are classified into different risk categories in line with the provisions of the Client
Classification section of the AML & CFT Procedures Manual. The following risk factors, interalia, are accounted for when considering the level of risk involved with each client
relationship: cumulative amount of funds deposited into the client account/accounts,
country of residence, nationality, results of World-Check screening etc. Depending on thelevel of risk assigned to the client, additional checks may be required for those clients,
falling within higher risk categories. Enhanced due diligence is conducted for such clients,
whereby the residential address, the source of funds and/or source of wealth, and anyother information deemed necessary, are verified additionally to the checks conductedwithin the standard due diligence. The classification of clients, according to their risk
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profile, then serves the Company to set the appropriate rules for ongoing monitoring of
the relationship and transactions. The detailed Client Due Diligence procedures are laid out
in the relevant section of the AML & CFT Procedures Manual;(d) following the necessary checks, and, based on the perceived level of risk, associated witheach client relationship, the decision is made to either proceed with a client’s application
or reject it. For all the clients classified as high-risk, an approval from either the MLCO, his
deputy or the CEO is required;(e) PEPs, their family members and close associates are classified as higher-risk and must
undergo enhanced due diligence procedure;(f) the Company’s Client Acceptance Policy (CAP) lays down the criteria for accepting of theclients. The detailed provisions of CAP are specified in AML & CFT Procedures Manual. The
following client categories, inter alia, are not accepted by the Company as clients (the list
below is not exhaustive):▪ where sufficient KYC information could not be obtained/confirmed or as per the risk
categorization;▪ the client matches the person in the sanction lists during World-Check screening andthe match is confirmed to be a true match by the designated compliance officer or the
MLCO;▪ the client matches the person in the lists with criminal records during World-Checkscreening and the match is confirmed to be a true match by the designated complianceofficer or the MLCO;▪ clients from countries on the list of non-cooperatives jurisdictions with FATF;▪ clients from USA and Mauritius;▪ client accounts are in names of companies, the shares of which are in bearer form;▪ the client is a Trust account.

12. ONGOING CLIENT MONITORING
The ongoing monitoring arrangements are comprised of two sets of measures:(1) First, the client records are kept up-to date, KYC information and documents are updated
regularly; these updates, for instance, include ongoing World-Check screening for all
existing client base. The client information updates may result in re-classification of theclient into a different risk category, in which case, the rules for ongoing monitoring overthis client relationship are re-set to align with the updated risk category;(2) In line with the risk classification of a client relationship, the transaction monitoring rules
are designed for the specific client, and ongoing monitoring of that client’s activity is
conducted manually by the relevant employees, in “real-time” and retrospectively.
13. INTERNAL AND EXTERNAL REPORTING
All employees must be aware of their obligation on reporting suspicious activity where they
have knowledge or grounds for suspicion. For further guidance on what constitutes grounds
for suspicion and what constitutes suspicious activity, please refer to the “Recognition andReporting of Suspicious Activity” section of the AML & CFT Procedures Manual.

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Tradit Ltd. is licensed and regulated by the FSC Mauritius lic. no GB21026376. The company is legally obliged to follow all laws of
the Republic of Mauritius and rules and conditions of the Mauritius Financial Services Commision.

In case of suspicion, all employees must fill in the Internal Suspicious Activity Report and send
it directly to the MLCO for further investigation. No transacting with the client who is the
subject of suspicion is allowed without the guidance from the MLCO. No disclosure is allowed,
apart from the MLCO and the line manager, to anyone within the Company or to the client, forprevention of tipping-off and committing an offence. The detailed procedure for submitting
Internal Suspicious Activity Report is outlined in the AML Procedures Manual.
The MLCO is responsible for reviewing all internal reports submitted to him and making a
judgement when the report to the FIU must be made.
If no report to FIU is made, the reason must be recorded by the MLCO. The MLCO or deputy
MLCO will commit a criminal offence if they know or suspect, or have reasonable grounds to
do so, through a disclosure being made to them, that another person is engaged in money
laundering and/or terrorist financing, and they do not disclose this as soon as practicable to the
FIU.

14. RECORD KEEPING
The retention of relevant records is done in line with the regulatory obligations in Mauritius,
and in line with the Company’s internal policy, outlined in the AML Procedures Manual.
The MLCO is in charge of keeping records of all referrals received and any action taken to ensure
an audit trail is maintained. All information obtained for the purposes of money laundering
checks and referrals must be kept up-to-date.

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support@axiory.com

Tradit Ltd. is licensed and regulated by the FSC Mauritius lic. no GB21026376. The company is legally obliged to follow all laws of
the Republic of Mauritius and rules and conditions of the Mauritius Financial Services Commision.

APPENDICESAPPENDIX 1. ASSOCIATED POLICIES AND PROCEDURES
1.
2.
3.
4.
5.
6.
7.
8.

AML & CFT Procedures Manual
Client Acceptance Policy (CAP)
Procedure for Internal Suspicious Activity Reporting
KYC and Client Due Diligence procedures
Know Your Employee (KYE) Policy
Operational guidelines for relevant business divisions
Document Retention Policy
Senior Management Structure, Roles and Responsibilities Statement

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Tradit Ltd. is licensed and regulated by the FSC Mauritius lic. no GB21026376. The company is legally obliged to follow all laws of
the Republic of Mauritius and rules and conditions of the Mauritius Financial Services Commision.

APPENDIX 2. GLOSSARY
AML

Anti-Money Laundering

CAP

Client Acceptance Policy

CEO

Chief Executive Officer

CFT

Combatting the Financing of TerrorismDD

Due Diligence

EDD

Enhanced Due Diligence

FATF

Financial Action Task Force

FCA

Financial Conduct Authority

FIU

Finance Intelligence Unit (of Mauritius)

JMLSG

Joint Money Laundering Steering GroupKYC

Know Your Client

KYE

Know Your Employee

MLCO

Money Laundering Compliance Officer

PEP

Politically Exposed Person

SYSC

FCA’s Systems and Controls

UN

United Nations

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support@axiory.com

Tradit Ltd. is licensed and regulated by the FSC Mauritius lic. no GB21026376. The company is legally obliged to follow all laws of
the Republic of Mauritius and rules and conditions of the Mauritius Financial Services Commision.